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Wise has a bachelor's degree in Business Administration from
Cleveland State University. He is a licensed Certified Public
Accountant (C.P.A.) in Ohio and Florida. Wise worked at Price
Waterhouse for 12 or 13 years. He was an audit partner for four
of those years.
Wise held a power of attorney from Eicher. At times the
power was unlimited and at times the power was specific.
The Wises and Eicher were calendar-year, cash basis
taxpayers.
B. The Pass-through Entities
1. Wesco
Wesco was a cash basis partnership formed in 1973, with a
fiscal year ending April 30. Wise and Eicher used Wesco
extensively as a depository or "bank" throughout most of its
existence. During Wesco's fiscal years 1988 and 1989, Wise held
40 percent and Eicher held 60 percent of Wesco's income, credits,
and deductions.
2. Hersco
Hersco was a calendar-year, cash basis partnership formed in
1973. During 1987 and 1988, Hersco did not have a bank account
or any recurring sources of liquid funds. During 1988, Wise held
37.5 percent and Eicher held 62.5 percent of Hersco's income,
credits, and deductions.
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Last modified: May 25, 2011